NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: aiam1376OpenHonorable Charles H. Percy, United States Senate, Washington, D.C. 20015; Honorable Charles H. Percy United States Senate Washington D.C. 20015; Dear Senator Percy: This is in reply to your communication of January 3, 1974, forwardin to us correspondence dated November 29, 1973, from Mr. Bruce Motyka of Des Plaines. Mr. Motyka requests information regarding laws relating to pickup trucks and camper weight limits, laws or studies relating to the sale of trucks exceeding GVW (Gross Vehicle Weight) rate minimums, and regulations or studies regarding maximum weights for tires.; The NHTSA has issued regulations relating to the installation o campers onto pickup trucks. Motor Vehicle Safety Standard No. 126 'Truck camper loading' (49 CFR S571.126) requires each camper to bear a permanent label containing information on its maximum loaded weight. The standard also requires each camper to be furnished with an owner's manual that contains information on total camper weight, the selection of an appropriate pickup truck, appropriate methods of camper loading, how to determine the camper's center of gravity and where it should be placed on the truck cargo area. A companion 'Consumer Information' regulation, 'Truck camper loading' (49 CFR S575.103) requires that written information be provided at the sale of each truck capable of being equipped with a slide-in camper that deals with the correct installation of a slide-in camper in that vehicle. This information is also required to be available in dealers' showrooms for retention by prospective purchasers of such trucks.; Other NHTSA regulation (49 CFR Part 567, 'Certification') require ever motor vehicle, including pickup trucks, to be labeled usually on the driver's door or door jam, with its gross vehicle weight rating, and the gross axle weight rating for each axle. Each of these ratings is intended to be based on the weight of a fully loaded vehicle, as determined by the vehicle's manufacturer. While it is possible for manufacturers to be incorrectly rate vehicles, and thus be in noncompliance with the regulations, we have not found this practice to occur in the case of pickup trucks.; There are also Federal requirements requiring motor vehicle tires t carry a load rating. Motor Vehicle Safety Standard No. 109 applies to passenger car tires and has been in effect since January 1, 1968. Motor Vehicle Safety Standard No. 119 applies to tires for all other types of motor vehicles (trucks, trailers, buses, motorcycles, and multipurpose passeng r(sic) vehicles) and will become effective September 1, 1974. This agency has conducted a study of the overloading of tires on recreational vehicles, and information regarding this study as well as copies of the safety requirements referred to above are enclosed.; We did not receive Mr. Motyka's earlier letter to us. As his question are of a general nature we have provided him with general answers. If his questions involved a particular problem we would be happy to provide further assistance.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4174OpenMs. Ann Boriskie, 6738 Firelight Lane, Dallas, TX 75248; Ms. Ann Boriskie 6738 Firelight Lane Dallas TX 75248; Dear Ms. Boriskie: Thank you for your letter of June 2, 1986, asking for approval of device you have invented which is designed to prevent children from inadvertently or intentionally opening the buckle of a safety belt. As you requested, the agency will not disclose the details of your proprietary product. Although we understand your concern that young children should not be able to easily get out of a safety belt, we have significant reservations about your product. I hope the following discussion explains those reservations and the effect of our regulations on your product.; Our agency has the authority to issue safety standards applicable t new motor vehicles and certain items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead the National Traffic and Motor Vehicle Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet our safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates other alleged safety-related defects.; Although we do not have any standards that directly apply to you product, we do have several statutory provisions that could affect it. Manufacturers of motor vehicle equipment such as your product are subject to the requirements in sections 151-159 of the Vehicle Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. The agency does not determine the existence of safety defects except in the context of a defect proceeding, and thus is unable to say whether your product might or might not contain such a defect. However, the agency has reservations about your product because of our concern that people be able to easily and quickly operate a safety belt in an emergency. As the agency said last year on the related topic of the force level necessary to operate buckles in child restraints:; >>>The agency's safety concerns over child restraint buckle forc release and size stem from the need for convenient buckling and unbuckling of a child and, in emergencies, to quickly remove the child from the restraint. This latter situation can occur in instances of post-crash fires, immersions, etc. A restraint that is difficult to disengage, due to the need for excessive buckle pressure or difficulty in operating the release mechanism because of a very small release button, can unnecessarily endanger the child in the restraint and the adult attempting to release the child. (50 FR 33722, August 21, 1985).<<<; Your product could significantly increase the difficulty of using th buckle release and thus hinder a person attempting to release the belt in an emergency.; In addition, use of your product can be affected by sectio 108(a)(2)(A) of the Vehicle Safety Act. That section prohibits commercial businesses from knowingly tampering with devices or elements of design installed in a vehicle in compliance with the Federal motor vehicle safety standards. One requirement of Standard No. 209, *Seat Belt Assemblies*, is that the pushbutton release for a safety belt must have a minimum area for applying the release force. Installation of your device by a commercial business could be prohibited since it apparently would substantially reduce the minimum area available for applying the release force to the safety belt pushbutton. In addition, Standard No. 302, *Flammability of Interior Materials*, requires new safety belts to meet a flammability resistance requirement. Thus, although Standard No. 302 does not directly apply to aftermarket equipment, commercial businesses could not install your device if it would mean that the safety belt no longer met the flammability resistance requirements of Standard No. 302.; The prohibition of section 108(a)(2(A) (sic) does not apply t individual vehicle owners who may install or remove any items of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, our policy is to encourage vehicle owners not to remove or otherwise tamper with vehicle safety equipment. Installation of your product by any person could be inconsistent with that policy.; I am returning, under separate cover, the samples of your device tha you sent the agency. If you have any further questions, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1726OpenMr. Robert L. Donnelly, Secretary, Armstrong Rubber Company, New Haven, Connecticut 06507; Mr. Robert L. Donnelly Secretary Armstrong Rubber Company New Haven Connecticut 06507; Dear Mr. Donnelly: This responds to your letter of May 30, 1975, concerning the standard applicable to a tire which you manufacture and sell with the designation L78-15LT, Load Range C.; You are mistaken in your assumption that a station wagon is classifie as a multi-purpose passenger vehicle. Because it is constructed neither on a truck chassis nor with special features for occasional off-road operation, a station wagon is a passenger car rather than a multi-purpose passenger vehicle.; If, despite this misunderstanding, the L78-15LT tire in question i designated by you as primarily intend for use on lightweight trucks or multi-purpose passenger vehicles, then it is a light truck tire subject to Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*.; Because a station wagon is a passenger car, Standard No. 110 require that its original equipment tires comply with Standard No. 109. Standard No. 110 is not applicable to used cars, so there is no prohibition on the use of the L78-15LT tire as replacement equipment on a station wagon. However, because the informational placard on a station wagon would suggest to its owner the use of inflation pressures which are dangerously inadequate for light truck tires, we do not wish to encourage the sale of such tires as replacement equipment for use on station wagons.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2809OpenMr. William Shapiro, Manager, Regulatory Affairs, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulatory Affairs Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro: This is in reply to your letter of May 3, 1978 asking whether there i any legal objection to Volvo's installation of red rear fog lamps on passenger cars it sells in the United States.; As you have noted, 'the only possible objection' to these lamps is th prohibition of S4.1.3 of Motor Vehicle Safety Standard No. 108 against the installation of lamps that impair the effectiveness of lighting equipment mandated by the standard. We have no basis for disagreeing with your opinion that the red 'rear fog lamps do not impair the effectiveness of other lighting equipment.' However, the lamps would be subject to the laws of the individual States.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0834OpenStanley D. Bynum, Esq., Bradley, Arant, Rose & White, 1500 Brown-Marx Building, Birmingham, AL, 35203; Stanley D. Bynum Esq. Bradley Arant Rose & White 1500 Brown-Marx Building Birmingham AL 35203; Dear Mr. Bynum: This is in reply to your letter of July 31, 1972, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'.; You ask whether your client is justified in assuring its customers tha the mattress ticking it manufactures complies with Standard No. 302 after a testing company has reported that it does. Whether a product must meet the requirements of a federal motor vehicle safety standard is determined by the 'application' section of each standard. Standard No. 302 is by its terms applicable to specific types of motor vehicles, and individual items of motor vehicle equipment are not included. Of course, components which are incorporated into motor vehicles covered by the Standard will normally be required by contract with the motor vehicle manufacturer to conform to all relevant standards before the first purchase by a user.; The basis upon which a manufacturer makes a determination that vehicle or component conforms to a standard is within his own discretion. The National Highway Traffic Safety Administration does not provide approval of any item of motor vehicle equipment as conforming to any motor vehicle safety standards.; You ask further, 'to what extent, if any, will the manufacturer of product which in its original state complies with federal law be held responsible for noncompliance despite alteration of the product by the ultimate consumer'. Generally, a manufacturer is not liable for the noncompliance of its product resulting from the alterations of a consumer. However, if the manufacturer could reasonably expect consumers to perform the alteration, then the NHTSA might consider the resultant nonconformity to be a safety related defect under the National Traffic and Motor Vehicle Safety Act.; Finally, you are correct in assuming that the NHTSA views 15 U.S.C S1397(b)(2) to mean that a 'manufacturer may escape the penalties contained in S1398 of title 15 upon a showing that it 'did not have reason to know in the exercise of due care' that its product was substandard'.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4524OpenMr. Ward W. Reeser Project Engineer Electrical Systems Caterpillar Tractor Co. 100 N. E. Adams St. Peoria, Illinois 61629; Mr. Ward W. Reeser Project Engineer Electrical Systems Caterpillar Tractor Co. 100 N. E. Adams St. Peoria Illinois 61629; "Dear Mr. Reeser: I am writing in response to your December 4, 198 letter in which you described Caterpillar Inc.'s worldwide program to review lighting used on Caterpillar product lines in order to standardize the devices. You specifically asked if any of Caterpillar's lighting devices were covered by Federal Motor Vehicle Safety Standard (FMVSS) 108. You enclosed descriptive literature on the Caterpillar product line. I regret the delay in responding to your question. It must be noted at the outset that the National Highway Traffic Safety Administration (NHTSA) issues safety standards for 'motor vehicles.' Therefore, Standard 108 and all of our other regulations apply to a vehicle and its manufacturer only if the vehicle qualifies as a 'motor vehicle' under the provisions of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.). Section 102(3) of the Act defines 'motor vehicle' as: any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. We have interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Agricultural equipment, such as tractors, are not motor vehicles because Congress clearly did not intend to include them in its coverage. Further, vehicles designed and sold solely for off-road use (e.g., Airport runway vehicles and underground mining vehicles) are not considered motor vehicles, even though they may be operationally capable of highway travel. On the other hand, vehicles that use the public highways on a necessary and recurring basis are motor vehicles. For instance, utility vehicles like the Jeep are plainly motor vehicles, even though they are equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, NHTSA has interpreted the vehicle to be a 'motor vehicle.' Further, if a vehicle is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, NHTSA has found the vehicle to be a motor vehicle. This finding was made with respect to dune buggies and regardless of the manufacturer's stated intent regarding the terrain on which the vehicles were to be operated. As noted above, this agency has consistently interpreted 'motor vehicle' to exclude vehicles that are equipped with tracks or are otherwise incapable of highway travel. Therefore, the track-type tractors, excavators, track-type loaders, tracked pavement profilers PR-450, PR-750B and PR-1000, concrete slipform pavers & auxiliary equipment, finegraders, front shovels, swing machines, tracked skidders D4H and D5H are not considered to be 'motor vehicles.' In your letter, you described the Caterpillar line of construction and industrial equipment as basically for off-highway use: 'There are occasional uses on the highway for such equipment as motor graders, but obviously none of this equipment is designed for normal highway use or for the transportation of people.' Despite their use of the highway, some vehicles are excepted from the motor vehicle classification. Highway maintenance and construction equipment, lane stripers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinguishes them from the traffic flow are not considered 'motor vehicles.' Although many items in the Caterpillar product line have an abnormal configuration that readily distinguishes them from other vehicles, the product literature enclosed with your letter did not provide sufficient information on the maximum speed capabilities or intended uses (i.e., strictly off highway or occasional on-highway use) of the motor graders, off-highway tractors, articulated dump trucks, wheel tractors, compactors, landfill compactors, wheel loaders, integrated toolcarriers, backhoe loaders, pavement profilers PR-75, PR-105 and PR-275, asphalt pavers & auxiliary equipment, compaction equipment, skidders, pipelayers, scrapers, and off-highway trucks to enable me to make a determination whether these would be considered 'motor vehicles.' However, I believe that the guidelines for classifying vehicles that are set forth above will allow you to determine if these are 'motor vehicles.' If they are, they must comply with safety standards, including Standard 108, applicable to trucks. The lighting devices and other features of 'motor vehicles' would be required to comply with the FMVSS (49 CFR Part 571). As you are aware, Standard No. 108, Lamps, reflective devices, and associated equipment (49 CFR 571.108) specifies requirements for original and replacement lamps, reflective devices, and associated equipment necessary for signaling andfor the safe operation of motor vehicles during darkness and other conditions of reduced visibility. Finally, the product literature included several items which did not appear to be self-propelling, including the asphalt drum mixers, aggregate bins, and compaction equipment items TSF-54 and TSM-54. These products fall within NHTSA's jurisdiction if they are 'trailers' as that term is defined at 49 CFR 571.3. That section defines 'trailer' as 'a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle.' Based on the depiction in the brochure, the equipment appear to be designed for carrying property (drum mixers, aggregate bins, and compaction equipment) and for being drawn by another vehicle. Therefore, whether the equipment are trailers depends on whether they are 'motor vehicles' within the meaning of the Safety Act and on whether the vehicles the equipment are designed to be drawn by are 'motor vehicles.' Specific information has not been provided about the intended uses of the equipment. If they make frequent use of the highways, and stay at one particular job site for a limited amount of time, the items mentioned above would be motor vehicles, and would fall within the definition of 'trailers.' Trailers are subject to Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. If, on the other hand, the equipment are intended to be drawn by vehicles that are not motor vehicles, or the equipment stays at a job site for extended periods of time and it travels on the highways only to move to another job site for an extended stay, the equipment would not be considered motor vehicles. It is important to note that NHTSA does not approve motor vehicles or motor vehicle equipment, nor do we endorse commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a 'self certification' process under which each manufacturer is required to certify that its products meet all applicable safety standards. The National Traffic and Motor Vehicle Safety Act prohibits the manufacture or sale of a noncomplying product. I hope the information provided above will be useful to you and to Caterpillar, Inc. If there are any further questions or if you need further information, please do not hesitate to write to me. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam2223OpenMr. John F. Evans, Wenke, Burge & Taylor, Suite 801, 1055 North Main Street, Santa Ana, CA 92701; Mr. John F. Evans Wenke Burge & Taylor Suite 801 1055 North Main Street Santa Ana CA 92701; Dear Mr. Evans: This is in response to your February 10, 1976, letter concerning th determination of Gross Vehicle Weight Rating (GVWR) and Gross Axle Weight Rating (GAWR) for boat trailers.; You have presented the following two examples: >>>GVWR -- 3300, GAWR -- 2970 and GVWR -- 3000, GAWR -- 2700. <<< Assuming that 10 percent of the trailer's loaded weight is carried b the towing vehicle, each example reflects a permissible relationship between the GVWR and the GAWR. Your letter indicates that your client presently provides a GVWR figure of 3000 pounds,; >>>based on the load carrying capacity determined when the trailer i *not* connected to a towing vehicle.<<<; If by this you mean that the boat trailer's axle system has a loa carrying capacity of 3000 pounds, then the trailer would actually be entitled to a GAWR of 3000 pounds and a GVWR of 3333 pounds. Your client is free, of course, to establish more conservative load ratings. However, the GAWR should not be less than 9/10 of the accompanying GVWR.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3961OpenMr. Joseph C. Bright, Jr., St. Peter's School, 319 Lombard Street, Philadelphia, PA 19147; Mr. Joseph C. Bright Jr. St. Peter's School 319 Lombard Street Philadelphia PA 19147; Dear Mr. Bright: This responds to your May 15, 1985 letter to Ms. Linda Marston, Healt and Human Services Regional Director for Region III. Your letter has been referred to my office for reply.; According to your letter, you were informed that federal law prohibit you from transporting more than 9 school children in vans. As a result of this, you believe that the seating in your 15-passenger vans must be restricted in some manner to carry only 9 pupils. You asked for assistance in relieving those restrictions on school transportation.; I appreciate this opportunity to clarify our regulations for schoo buses.; As explained below, there is no federal law prohibiting you fro transporting school children in a 15-passenger van. Federal law does, however, affect the sale of buses to schools. The National Highway Traffic Safety Administration (NHTSA) has the authority, under the National Traffic and Motor Vehicle Safety Act of 1966, to regulate the manufacture and sale of new motor vehicles and new motor vehicle equipment. Congress amended the Vehicle Safety Act in 1974 to direct NHTSA to issue motor vehicle safety standards on specific aspects of school bus safety, such as emergency exits, seating systems, windows and windshields, and fuel systems. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date.; The parties subject to the requirements of the Vehicle Safety Act ar the sellers of new school buses. The Vehicle Safety Act requires any person selling a new bus to a school to sell a bus that complies with our motor vehicle safety standards for school buses or be potentially subject to fines under Federal law for selling noncomplying vehicles.; Our definition of a 'school bus,' as found in the definitions sectio of our motor vehicle safety standards (49 CFR S571.3), is as follows:; >>>'School bus' means a bus that is sold, or introduced in interstat commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed for operation as a common carrier in urban transportation.<<<; Our definition of a 'bus,' also found at 49 CFR 571.3, is 'a moto vehicle with motive power, except a trailer, designed for carrying more than 10 persons.'; Thus, the 15-passenger vans that you operate are 'school buses' unde the Federal definition. Federal law required the seller of new 15- passenger vans to ensure that those vans complied with the school bus safety standards when those vans were sold to the St. Peter's School. There is no Federal prohibition directed against you, however, that restricts you from transporting more than 9 students in a van. Since our authority under the Vehicle Safety Act does not extend to the use of school buses by school districts or individual schools, our regulations do not prohibit you from using 15-passenger vans as school vehicles.; From our correspondence with Pennsylvania and with various schoo districts, we are aware that Pennsylvania has adopted our definition of a 'bus' in Act 1984-146. In doing so, it has extended the reach of state school bus regulations to cover vans with a capacity of 10 passengers and a driver. This recent change in Pennsylvania law does not affect how our regulations applied to the sale of your 15-passenger vans. Your vehicles were always classified as 'school buses' under Federal law, and the persons selling the vans are potentially liable for selling noncomplying buses to St. Peter's School. I have enclosed for your information a letter dated February 12, 1985, from our office to your school concerning our regulations.; Please let me know if you have further questions. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2673OpenMr. Eric E. Gough, Staff Assistant (Technical), Lucas Industries North America, Inc., Two Northfield Plaza, Troy, MI 48084; Mr. Eric E. Gough Staff Assistant (Technical) Lucas Industries North America Inc. Two Northfield Plaza Troy MI 48084; Dear Mr. Gough: In response to your letter of August 19, 1977, we advise you that you mistake in referencing S4.5.2 of Standard No. 108 instead of S4.5.1 in your earlier letter of May 13, 1977, does not alter our previous interpretation of June 16, 1977.; Your design appears to meet the specifications of J564a allowin compliance of the headlamp beam switching system with S4.5.1 when installed in a motor vehicle.; Sincerely, Frank Berndt, Deputy Chief Counsel |
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ID: aiam2389OpenMr. William R. Rodger, Vice President, Advanced Programs, Rockwell International, 2135 West Maple Road, Troy, MI 48084; Mr. William R. Rodger Vice President Advanced Programs Rockwell International 2135 West Maple Road Troy MI 48084; Dear Mr. Rodger: This responds to Rockwell International's February 23, 1976, reques for confirmation that the deactivation of automatic adjusters is acceptable during burnish procedures of Standard No. 121, *Air Brake Systems*, at the option of the manufacturer.; The procedure that you recommend is not permitted by any provision o Standard No. 121. The NHTSA would consider some provision to deal with the overadjustment of automatic adjusters upon receipt of technical data showing justification for such action. Based on consideration of the data received and a petition for amendment, the agency could commence a rulemaking proceeding in accordance with established procedures.; It should be noted that the option in FMVSS 105-75 that you describ requires that the automatic adjusters be deactivated for the entire test sequence, not just the burnish procedure.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.